| Comment Number: | 522418-13267 |
| Received: | 9/29/2006 7:47:21 PM |
| Organization: | Quackwatch |
| Commenter: | Stephen Barrett |
| State: | PA |
| Subject: | Business Opportunity Rule |
| Title: | Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Part 437 |
| Attachment: | 522418-13267.pdf Download Adobe Reader |
Comments:
The Direct Selling Association, most of whose members are companies that do multilevel marketing, has submitted a lengthy statement #2882-2892) with this conclusion: “DSA supports and shares the FTC’s goal of ridding the marketplace of fraudulent business opportunities. The proposed rule, however, would cast far too wide a net and in doing so would harm and possibly destroy many legitimate, lawful direct sellers. The proposed rule would also likely unnecessarily discourage many prospects from pursuing beneficial direct selling activities. Therefore, if the FTC continues to pursue a separate business opportunity rule, DSA urges the FTC to exclude from its requirements those legitimate, lawful companies that use the direct selling business model. . . . Direct selling companies are not sellers of business opportunities and should be exempted from any business opportunity fraud rule. “ This statement is preposterous. I have investigated more than 150 companies that sell health-related products. All were promoted with glowing but deceptive accounts of how much money can be made. In an age where the public demands accountability, nobody should be exempt. I have attached additional suggestions.